OSHA held the first of two stakeholder meetings this week to gather input for what it calls “modernizing” occupational safety and health recordkeeping.

OSHA has raised these issues:

  • What recordkeeping data should the electronic recordkeeping system collect?

  • Would linking the recordkeeping data with other sources (e.g., medical records, workers' compensation records) increase its usefulness and/or accuracy? If so, which sources? What potential technical and legal hurdles exist in linking to other data sources, and how might these be overcome?

  • Should the electronic recordkeeping system collect data from every employer under OSHA jurisdiction for every case, or should it be limited to a subset of employers and/or cases, for example based on size, industry, incidence rate, occupation, or case severity?

  • What purposes could the collected recordkeeping data serve for OSHA as well as other users?

  • How could the collected data be used to make national or sector-specific estimates of injury and illness?

  • What would be the strengths and limitations of the collected data?

  • Would publishing data indicating the number of employees and number of employee hours worked at specific establishments disclose confidential commercial or trade secret information?

  • How can OSHA use state and other federal agency data collection experience in developing an electronic recordkeeping system?

  • How should OSHA design an effective quality assurance program for data entered into the electronic recordkeeping system?

  • Should data be collected on a flow basis or periodically, e.g., quarterly? What are the advantages and disadvantages of each approach to data collection?

  • What would be the benefits and disadvantages of implementing a new electronic recordkeeping system incrementally, e.g., starting with the largest employers or the most severe injuries?

  • What training and outreach will be necessary for employers to comply with the requirements of the electronic recordkeeping system?

  • How can OSHA ensure that small-business employers are able to comply with the requirements of the electronic recordkeeping system?

  • What analytical tools could be developed and provided to employers to increase their ability to effectively use the injury and illness data?

  • How can OSHA improve the accuracy of recordkeeping data by encouraging reporting and recording of work-related injuries and illnesses and discouraging underreporting and underrecording of work-related injuries and illnesses?

The meetings take the form of group discussions. OSHA is not allowing formal presentations. There will be two sessions at each meeting, each accommodating approximately 25 participants and lasting about four hours.